We’ve created a list of frequently asked questions about Scotland’s Deposit Return Scheme (DRS). 

The Scheme

You’ll find details of the scheme’s design on the Zero Waste Scotland website.

Drinks producers and importers are responsible for delivering the scheme and Circularity Scotland has been created to administer the scheme on their behalf. Retailers also have a key role to play, operating the return points  and handling the return of deposits. All  drinks producers and importers must be registered with SEPA (Scotland’s Environmental Protection Agency) who will regulate the scheme.

Currently, the launch of the scheme is anticipated to take place on 1 July 2022, however this may change depending on the outcome of a review currently being undertaken by the Scottish Government.

All of the containers collected will be recycled. Collecting them in this way ensures that they are not contaminated with other waste. This means they can be recycled in the most efficient way possible and the materials can be used to make more drinks containers. This is known as “closed loop” recycling and forms an essential part of a circular economy where nothing is wasted and energy use is minimised.

Cashflow

The deposit has been set by Scottish Government at 20p within the Deposit and Return Scheme for Scotland Regulations 2020. For the sake of simplicity and clarity it has been set at the same price for containers of all sizes, made from all, in-scope, materials.

The figure of 20p was arrived at for a number of reasons. Firstly, it is enough to incentivise consumers to do the right thing and return their containers but it’s not so much that it will deter purchase. 

The figure is also in line with successful deposit return schemes around the world and it emerged as the optimal deposit level during extensive public consultations by the Scottish Government.  

The scheme has been carefully designed to be largely self-funding but, ultimately, the producers/importers/brand owners of the containers will have to pay a little to ensure that what they produce doesn’t have a negative effect on the environment. Additional income from the sale of the recyclable materials collected and unredeemed deposits will also help fund the scheme. These revenues will fluctuate from year to year and the producer fee will be adjusted annually to reflect this.

Timings

Currently, the scheme is scheduled to go live with the public from 1 July 2022 however the date is subject to review by the Scottish Government. If you’d like us to keep you up to speed with any changes, why not register your details with us.

 

Return Point Operators

Yes. For the scheme to work seamlessly, we will need to reimburse you from scheme funds for the deposits you pay and monitor what is collected from your return point.

You will be able to register online. You’ll just need to tell us where you are, so we can arrange collections, and whether you are planning to operate a manual return point or an RVM. We’ll also need to know your opening hours, any access restrictions and how you want to be paid.

You can sign up to receive updates and be notified when the formal registration process opens. This will ensure you have ample time to work out the best solutions for your business and for us to help you prepare. Ultimately, there will be over 35,000 return points across Scotland, so don’t leave it to the last minute. Remember, it will be illegal to sell drinks after the launch date unless your business is fully compliant with the DRS Regulations.

The formal registration process will take place in 2022. 

 

Yes. Circularity Scotland will work with all return points and those businesses operating take-back services.

Under the DRS regulations, there is no obligation for return point operators to utilise reverse vending machines. It is up to individual retailers and venues hosting return points to decide whether they wish to install a reverse vending machine or accept returns manually. Generally speaking, a reverse vending machine only makes economic sense if you are handling a high volume of returns. More information and guidance will be set out by Circularity Scotland for return point operators in due course.

The specifications for reverse vending machinery for the scheme will be announced in February 2022 to give Return Point Operators time to procure the correct equipment.

It is up to Return Point Operators to select and buy or lease their own RVM, ensuring that it complies with the specifications produced by Circularity Scotland.

Yes. Every return point has to accept every item that is included in the scheme. This ensures that consumers can return their recyclable bottles and cans and retrieve their deposits wherever they are in Scotland. People buying deposit bearing products from your business will be allowed to return the containers to any other return point in Scotland.

Retailers

Online retailers must charge the 20p deposit on all drinks sold in PET plastic, glass and metal containers. They are also required to offer a free take-back service, collecting deposit-bearing products they have sold and refunding their customers. This is to ensure that the scheme is accessible for all, including those who rely on home deliveries. Online retailers’ customers will still be able to take their empty containers back to any other return point. As such, it is anticipated that the vast majority of customers will make use of a local return point, rather than a takeback service.

 

There are some exemptions. The main one will be where there is another return point in the immediate vicinity which volunteers to accept responsibility for their collection duty. This is most likely to be in transport terminals, food courts and shopping centres.

The exemption process is being managed by Zero Waste Scotland

There will be an app created to help you and your staff identify what is included in the scheme and what is not.

Hospitality

You will need to charge a deposit on all the containers included under DRS legislation and operate a return point that will accept any deposit-bearing containers . Because some of your containers will be going off-site and going to other return points you have a legal responsibility to accept containers that are presented to you. Customers paying deposits, and consuming the product on-site, can simply redeem it by presenting the empty container to your return point.

If all the drinks are consumed on site and you can collect them on site, you do not need to operate a return point.You can simply get the scheme administrator to collect all your deposit-bearing containers and refund the deposits you have paid your supplier or the producer.

Yes. We will need to know where you are so we can arrange for collections of returned containers. We’ll also need to reimburse you for the deposits you will have paid out and you’ll be due handling fees to cover any costs incurred operating the return point.

Voluntary

Voluntary return points applications are managed by Zero Waste Scotland. You can find out how to apply to set up a voluntary return point at their website.

If you succeed in getting approval from Scottish Government ministers, you will be able to register your Voluntary Return Point with Circularity Scotland.

 

Anyone can apply to operate a voluntary return point provided they can prove that they have sufficient operational and financial plans in place to set up and run the return point for at least one year.  They will need to show that they have funds in place to pay startup costs and that they can cover costs not reimbursed through the handling fee.

They will also need to show that they have carried out an analysis of the number of containers they will return in the average month. This could be based on factors such as the sales volume of exempted retailers for whom you will be providing an alternative return point. If your Voluntary Return Point is in a transport hub or shopping centre, your proposal could be based on the footfall of passengers or shoppers passing through the facility.  

 

Collections

We aim to repay deposits paid out by return point operators within 7 days of collecting their containers. 

For manual return points, the payment process is triggered when the containers collected have been processed at the counting centre.  For automatic return points (RVMs), it is when the sacks or bags have been scanned on arrival at the counting centre. You can find out more about the cashflow through the Deposit Return Scheme here.

We are committed to offering the same level of service to return points at all locations across Scotland - no matter how remote.

Yes. If you find you have an unusually high level of returns, you will be able to request additional collections through either the return point operator app, the Circularity Scotland website or by calling the customer call centre. If it becomes clear that your collection volumes are low or unpredictable, you may find an ad-hoc collection is preferable, rather than a regular cycle.  There will be agreed timeframes for such collections.

We recognise that events such as music festivals or sports matches may result in the need for return points with limited storage being overwhelmed. In this case we will arrange for additional collections whenever needed.

Producers

Not necessarily. If you register with Circularity Scotland, we will register your business with SEPA and undertake reporting duties on your behalf. If, however, you don’t register with Circularity Scotland, you will have to register with SEPA and fulfil their reporting requirements yourself.

Yes. Everyone producing any amount of drinks for sale on the Scottish market in PET plastic, glass or metal containers between 50ml and 3 litres is legally required to take part in the scheme.

No. You can choose to administer the scheme yourself but the costs and complexity of doing this yourself are likely to prove onerous. This is why the drinks industry has come together to create a single scheme administrator in the form of Circularity Scotland.

Financial contributions will take the form of a producer fee, charged on each drinks container placed on the market. The level of the producer fee will be determined at a later date by Circularity Scotland. 

We aim to be able to advise producers with an initial view of the likely range of producer fees by Spring 2022 but a definitive figure will be set closer to the time when the  scheme goes live. This is due to the complexity of implementing the scheme and variability in the value of recycled materials. The fee will be reviewed annually.

Circularity Scotland operates as an independent, not-for-profit company. It will run a professional, fair and highly efficient scheme that meets the collection targets laid out in the DRS Regulations while keeping producers’ fees as low as possible. Circularity Scotland is currently determining the exact producer fee and will communicate this to registrants as soon as possible.

Circularity Scotland will set out more information for producers in due course. The sign up process is now open & you’ll be able to start the formal registration process during 2022. 

Under the DRS Regulations, producers who are not using us as their scheme administrator are required to register with SEPA from January 2022 onwards. If producers choose to appoint a scheme administrator, this will be carried out on their behalf and registrations with Circularity Scotland will start in 2022. Circularity Scotland advises producers wishing to appoint it as their scheme administrator to sign up with us now to help get your businesses ready for formal registration. 

No, The Scottish Government’s Deposit Return Scheme (DRS) legislation defines a producer as “The Brand owner”, or where the brand owner is outside the UK, “the importer”.

Producer Agreement

All producers will be treated equally and have the same agreement whatever size they are. Because the producer fee is set per container, everyone pays for the scheme according to what they produce.

Currently, the producer agreement is still being finalised, It will be available to download from the restricted documents section of our website. Sign up for updates and you will automatically be informed when it becomes available.

Producer Registration

We anticipate that we will be able to start registering producers during 2022 . Sign up to find out when you can start your full registration process.

Ideally, you should register as soon as you are able. There is no fixed deadline but, to trade legally after the launch date, you will need to have everything required by the regulations in place and operating smoothly.

Based on other similar systems operating in Europe, we estimate it will take six weeks to fully process registrations, and we estimate that over 4,500 producers will be registering through us, as scheme administrators, so we would advise starting the registration process as soon as our systems go live.

Producers may add and amend product details online provided you meet the regulatory obligations and timescales. Any new additions or amendments you make will result in a workflow alert to a member of our Customer Services team so it can be verified and accepted. 

Producers can delist product details online provided they meet rules relating to timing.  Delisting will trigger a workflow alert so it can be verified and checked by a member of our Customer Services team.

About Us

Organising a deposit return from scratch is a complex task and while individual producers are able to make their own arrangements to meet the new legal obligations, it makes financial and environmental sense to combine forces to create a single, world-class system. Circularity Scotland offers drinks producers efficiencies and economies of scale that would be hard to achieve independently. We also have the resources to bring insights and learning from the 40 other DRS operating in states and regions around the world to create the very best systems possible for Scotland. 

Circularity Scotland brings together major drinks producers from both the alcoholic and non-alcoholic sectors along with drinks wholesalers and retailers. There are also a number of trade bodies representing businesses producing or selling smaller volumes of packaged drinks. It is in all of their interests to ensure that the administrator operates as fairly as possible and meets their legal requirements efficiently and economically. 

Scheme Administrator

The DRS Regulations allow for drinks producers and importers to nominate a scheme administrator to act on their behalf and fulfil their obligations. These include refunding return point operators and organising collections of empty containers from their premises. 

As scheme administrator, Circularity Scotland will also manage the financial flow of fees and deposits, arrange the sale of recyclable materials from returned containers and other administrative and reporting functions.

 

Circularity Scotland will work with companies throughout the supply chain to create the best possible systems. By pooling everyone’s resources in a single scheme administrator, we can develop the most efficient and economical solutions. 

This will ensure that consumers are presented with a single clear and consistent identity so they know exactly what to do with their empty drinks containers. This coherent approach is more likely to meet the Government’s aspiration of collecting more than 90% of Scotland’s drinks containers.

Payment will take the form of a small fee - paid for by producers - which will be charged on every drinks container entering the market. The level of this fee will be set annually by Circularity Scotland and will reflect the prices realised for the recyclate collected in the scheme. The better the market for recycled materials, the lower the fee will be.

Membership of Circularity Scotland

Circularity Scotland is a not-for-profit Company Limited by Guarantee with members drawn from the producer and wholesaler community, based on production volume, and the retailer community (based on collection volume and numbers of return points). 

The company's legal setup requires us to have members. 

It was important for us to have a broad representation of members from across the key sectors affected by the deposit return scheme. This gave us an indication of support for the approach we are taking to fulfil the duties of scheme administrator.  

No. The initial members of Circularity Scotland include trade associations representing dozens of other companies. Membership also remains open to others who wish to join in their own right and meet the qualifying criteria. 

No, producers do not need to be a member of Circularity Scotland to appoint us as their scheme administrator. Likewise, return point operators will be offered service contracts by Circularity Scotland irrespective of their membership status.

Membership of Circularity Scotland is open to producers and return point operators in Scotland, or their trade associations, who meet qualifying thresholds.

For producers, placing more than 10 million containers onto the market in Scotland on an annual basis qualifies for membership.

For return point operators, taking back more than 20 million containers on an annual basis and/or responsibility for more than 500 return points in Scotland on an annual basis, qualifies for membership.

Trade associations representing members who collectively place more than 10 million containers in the territory qualify for membership. Alternatively, those representing members who collectively are responsible for either taking back more than 20 million containers via a return service and/or who collectively are responsible for more than 500 return points in the territory on an annual basis, qualify for membership.

Regardless of membership status, companies will be able to appoint us to act on their behalf to fulfil obligations under the DRS Regulations 2020.

Circularity Scotland is constituted as an independent, not-for-profit company. The very nature of an independent Scheme Administrator is to ensure that no party has an advantage over another and that the scheme is inclusive and run as efficiently and effectively as possible.

We will be led by an independent board of experienced directors and a team of professional executive staff. Members will not manage the day-to-day running of the company or operational aspects of the deposit return scheme. 

Producers and return point operators who do not wish to join as members themselves – or who do not meet the qualifying thresholds – can nominate another organisation or member to represent them within the governance of Circularity Scotland. This is through either a trade association or an approved nominee member.

Members cannot derive any benefit – financial or otherwise – over those who simply ‘appoint’ us as their scheme administrator. There is no obligation on producers to be a member of Circularity Scotland to appoint us as their scheme administrator. Likewise, return point operators will be offered service contracts by Circularity Scotland irrespective of their membership status.

There is no joining fee for members of Circularity Scotland. As a ‘company limited by guarantee’, the liability of any member of the company is limited to £1.